ILTA, ACC Submit Joint Comments on OLD RTR to EPA
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ILTA, ACC Submit Joint Comments on OLD RTR to EPA

December 5, 2019
U.S. Environmental Protection Agency
EPA Docket Center
Mail Code 28221T
1200 Pennsylvania Avenue NW
Washington, DC 20460

Submitted electronically to the Federal e-Rulemaking Portal (

RE: Comments on Proposed National Emission Standards for Hazardous Air Pollutants:
Organic Liquids Distribution (Non-Gasoline) Residual Risk and Technology Review
Docket ID No. EPA-HQ-OAR-2018-0074, 84 Fed. Reg. 56288 (October 21, 2019).

The American Chemistry Council (“ACC”) and the International Liquid Terminals Association (ILTA)
respectfully submit these comments on the U.S. Environmental Protection Agency’s (“EPA”) proposed
National Emission Standards for Hazardous Air Pollutants (NESHAP): Organic Liquids Distribution
(OLD) (Non-Gasoline) Residual Risk and Technology Review (84 Fed. Reg. 56288, October 21, 2019)
(“proposed standards”).

ACC and ILTA agree with EPA’s determination that risk from the OLD source category is acceptable and
that no changes to the standards are necessary to provide an ample margin of safety. Implementation of
the underlying NESHAP has been successful. Despite finding very low risk from the source category,
EPA has proposed to increase the regulatory burden of the standards. We offer explanations of our
disagreements with the Agency’s proposal as well as further suggestions and comments to support and
improve upon the Agency’s determinations.  

Please see the full comments attached.


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